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SEC Comment Letter 0000000000-25-007135 to ISRAEL, STATE OF (CIK 0000052749)

ISRAEL, STATE OF (CIK 0000052749)
Date: July 7, 2025 · CIK: 0000052749 · Accession: 0000000000-25-007135

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File numbers found in text: 333-287961

Date
July 7, 2025
Author
Division of
Form
UPLOAD
Company
ISRAEL, STATE OF (CIK 0000052749)

Letter

Re: Schedule B filed June 11, 2025 File no. 333-287961 Dear Elinor Azani:

July 7, 2025

Elinor Azani Head of Israel Economic Mission Western Hemisphere Schedule B filed June 11, 2025 Ministry of Finance, State of Israel 800 Second Avenue, 17th Floor New York, NY 10017

We have reviewed your registration statement and have the following comment(s).

Please respond to this letter by amending your registration statement and providing the requested information. If you do not believe a comment applies to your facts and circumstances or do not believe an amendment is appropriate, please tell us why in your response.

After reviewing any amendment to your registration statement and the information you provide in response to this letter, we may have additional comments.

Where You Can Find More Information About the State of Israel, page 1 General

1. Please revise this section to provide a separate link for each of the previously filed Form 18-Ks that are incorporated by reference. Form 18-K Filed June 30, 2025, page 1

2. Please review and revise this section to incorporate the appropriate pages from Exhibit D into your Form 18-K. For example, the cross-referenced pages for Item 6 does not include receipts, classified by source, and expenditures, classified by purpose. As another example, the cross-referenced disclosure for Item 8 does not include information about gold reserves. 3. Please provide the disclosure in Item 9 of Form 18-K that is incorporated from Tables 18 and 19 of Exhibit D by country, if practicable. Please see Item 9 of Form 18-K. 4. You state on page D-12 of Exhibit D that "[i]n 2023, the TA-35 and TA-125 indices increased by 28.4% and 28.6%, respectively..." This growth appears to have occurred July 7, 2025 Page 2

during 2024. Please clarify or revise. 5. You state on page D-13 that your "Green Bond Framework...has been developed to be aligned with best sustainable practices and has been favorably evaluated by CICERO Shades of Green, an internationally recognized Second Party Opinion ( SPO ) provider for green bonds. In the SPO delivered to Israel and published in November 2022, CICERO Shades of Green assigned the Framework an overall shading of Dark Green (its highest rating) and a governance score of Good . Israel s Framework is aligned with the International Capital Market Association s 2021 Green Bond Principles (the ICMA Green Bond Principles ), as was indicated by the SPO." Please file a consent pursuant to Rule 436 of the Securities Act for CICERO Shades of Green or tell us why you believe you are not required to do so. 6. You state on page D-61 of Exhibit D that "[e]xports of goods and services are crucial to the overall performance and competitiveness of Israel s economy" and that "[i]n 2024, services constituted 54.3% ($83.35 billion) of total exports, while goods constituted 45.7% ($70.2 billion)." Please explain the reasons for significant fluctuations in the export of goods and services discussed on page D-61 and presented in Table 16 of Exhibit D. To the extent practicable, please provide tabular disclosure of your export of services. We remind you that the company and its management are responsible for the accuracy and adequacy of their disclosures, notwithstanding any review, comments, action or absence of action by the staff.

Refer to Rules 460 and 461 regarding requests for acceleration. Please allow adequate time for us to review any amendment prior to the requested effective date of the registration statement.

Please contact Angie Kim at 202-551-3535 or Michael Coco at 202-551-3253 with any other questions.

Sincerely,
Division of
Corporation Finance
Office of
International Corporate
Finance

Show Raw Text
<DOCUMENT>
<TYPE>TEXT-EXTRACT
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<TEXT>
 July 7, 2025

Elinor Azani
Head of Israel Economic Mission Western Hemisphere
Schedule B filed June 11, 2025
Ministry of Finance, State of Israel
800 Second Avenue, 17th Floor
New York, NY 10017

 Re: Schedule B filed June 11, 2025
 File no. 333-287961
Dear Elinor Azani:

 We have reviewed your registration statement and have the following
comment(s).

 Please respond to this letter by amending your registration statement
and providing
the requested information. If you do not believe a comment applies to your
facts and
circumstances or do not believe an amendment is appropriate, please tell us why
in your
response.

 After reviewing any amendment to your registration statement and the
information
you provide in response to this letter, we may have additional comments.

Where You Can Find More Information About the State of Israel, page 1
General

1. Please revise this section to provide a separate link for each of the
previously filed
 Form 18-Ks that are incorporated by reference.
Form 18-K Filed June 30, 2025, page 1

2. Please review and revise this section to incorporate the appropriate
pages from Exhibit
 D into your Form 18-K. For example, the cross-referenced pages for Item
6 does not
 include receipts, classified by source, and expenditures, classified by
purpose. As
 another example, the cross-referenced disclosure for Item 8 does not
 include information about gold reserves.
3. Please provide the disclosure in Item 9 of Form 18-K that is
incorporated from Tables
 18 and 19 of Exhibit D by country, if practicable. Please see Item 9 of
Form 18-K.
4. You state on page D-12 of Exhibit D that "[i]n 2023, the TA-35 and
TA-125 indices
 increased by 28.4% and 28.6%, respectively..." This growth appears to
have occurred
 July 7, 2025
Page 2

 during 2024. Please clarify or revise.
5. You state on page D-13 that your "Green Bond Framework...has been
developed to be
 aligned with best sustainable practices and has been favorably evaluated
by CICERO
 Shades of Green, an internationally recognized Second Party Opinion (
SPO )
 provider for green bonds. In the SPO delivered to Israel and published
in November
 2022, CICERO Shades of Green assigned the Framework an overall shading
of Dark
 Green (its highest rating) and a governance score of Good .
Israel s Framework is
 aligned with the International Capital Market Association s 2021 Green
Bond
 Principles (the ICMA Green Bond Principles ), as was indicated by
the
 SPO." Please file a consent pursuant to Rule 436 of the Securities Act
for CICERO
 Shades of Green or tell us why you believe you are not required to do
so.
6. You state on page D-61 of Exhibit D that "[e]xports of goods and
services are crucial
 to the overall performance and competitiveness of Israel s economy"
and that "[i]n
 2024, services constituted 54.3% ($83.35 billion) of total exports,
while goods
 constituted 45.7% ($70.2 billion)." Please explain the reasons for
significant
 fluctuations in the export of goods and services discussed on page D-61
and presented
 in Table 16 of Exhibit D. To the extent practicable, please provide
tabular disclosure
 of your export of services.
 We remind you that the company and its management are responsible for
the accuracy
and adequacy of their disclosures, notwithstanding any review, comments, action
or absence
of action by the staff.

 Refer to Rules 460 and 461 regarding requests for acceleration. Please
allow adequate
time for us to review any amendment prior to the requested effective date of
the registration
statement.

 Please contact Angie Kim at 202-551-3535 or Michael Coco at 202-551-3253
with
any other questions.

 Sincerely,

 Division of
Corporation Finance
 Office of
International Corporate
 Finance
</TEXT>
</DOCUMENT>